BOI ES SCHI LLER t FLEXNER LLP 401 EAST LAS OLAS BOULEVARD • SUITE 1200 • FORT LAUDERDALE. FL 33301 22 • PH 954 $1 5 6 MC C• • FA X, t 254 356 0022 rid C sci. snictawIevAThstlin.com January 30, 2017 Confidential Sealed Filing VIA EMAIL & FACSIMILE: Honorable Judge Robert W. Sweet District Court Judge United States District Court 500 Pearl Street New York, NY 10007 SweetNYSDChambersQnysd.uscourts.gov Re: v. Maxwell, Case No.: 15-cv-07433-RWS Dear Judge Sweet, This is a reply letter in support of Ms. letter motion to allow for the newly- discovered witness, I to be called as a witness at trial because she can testify about Defendant's involvement in Epstein's sex trafficking ring based on first-hand experiences and first-hand observations. Defendant Violated Rule 26 By Failing To Disclose This Critical Witness Defendant argues that Ms. is somehow to blame for the fact tha is only now being discussed as a witness in this case. But Ms. only recently learned about this witness because Defendant failed to properly disclose her months earlier. In her response, Defendant does not address the fact that Ms. and Ms. Maxwell know each other. Indeed, Defendant does not address the fact that and she s nt time together on Mr. Epstein's private island, as reflected in the flight logs showing flying to and from the island (where Ms. Maxwell was present): _-i—g_ i t le12.;?-apz" lisstx91`4"ri V). De _AU)/ 4 ' _ -]21_ 1•z' ---i-- .rav\ tit lb IGAISMO NMOcl•Tal 1 6 -WC 11-ST I Mn UM t' 1 ‘ 1-its—Ad aiti_a_j_..111 all I' " Cr e . MT f ilea) €2.1 i I'' " (3Bi L Sf ..”22.; giNTh -1 ri -Ii II Ow% : Tr-s-r e--valt Ito)? Iretry tnn fl skoriale Ma by kiemtlft brim cmo law. G<japeto Loccutez G4StiALO 14“conT 4/ I _4+ ca • wwW.EiSFLLP Com EFTA00590749